Interpretation ID: nht76-5.20

DATE: 06/30/76

FROM: J. WOMACK FOR F. BERNDT -- NHTSA

TO: Toyota Motor Sales U.S.A. Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your March 24, 1976, letter concerning the label required by @ 567.4(g) of 49 CFR Part 567, Certification.

The certification label is required by paragraph (g) (3) to include "'GROSS VEHICLE WEIGHT RATING' or 'GVWR' followed by the appropriate value in pounds . . ." Paragraph (g) (4) specifies a similar requirement for Gross Axle Weight Ratings.

You have pointed out that the Canadian motor vehicle safety regulations require a similar certification label with these weight ratings expressed in kilograms. You have asked whether a single label that expresses the weight ratings in both pounds and kilograms would be permitted by 49 CFR Part 567. The answer is yes, provided that each kilogram rating, which is optional, appear after the corresponding pound rating, which is required.

Please note that these two ratings differ in legal status. The rating that is expressed in pounds is the official rating for the purposes of the United States Federal motor vehicle safety standards and regulations. The accompanying equivalent kilogram rating, however, will be considered as optional, supplementary information provided for the guidance of the reader. This distinction is necessary, because the measurement values, including weights, that appear in our safety standards and regulations are specified in exact terms, without tolerances. While a measurement in English units can be "equal" to one in metric units to any preselected number of significant figures, the two can never be exactly equal.